Japan Enacts its 2026 Tax Reform: an Article-by-Article Commentary on the Pillar Two Amendments

On March 31, 2026, Japan enacted its 2026 Tax Reform Package. This includes amendments to the Pillar Two regime including providing for aspects of the January 2026 Side-by-Side tax package (excluding the Simplified ETR Safe Harbour) and the January 2025 OECD Administrative Guidance.
Australia’s March 2026 Pillar Two technical amendments: an item-by-item analysis

On March 25, 2026, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 1) Rules 2026, to amend its Pillar Two rules to incorporate aspects of the OECD Administrative Guidance for DMTT purposes.